Overview -

Section 926 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) requires the Securities and Exchange Commission (“SEC”) to adopt rules that would make the exemption from registration under the Securities Act of 1933 (“Securities Act”) provided by Rule 506 of Regulation D thereof unavailable for any securities offering in which certain “felons” or other “bad actors” are involved. Effective September 23, 2013, the SEC adopted bad actor disqualifications provisions codified under section (d) of Rule 506.